When Can a Seized Vehicle Allegedly Carrying PDS Rice Be Released Pending Confiscation Proceedings? Reiteration and Application of Existing Precedents by the High Court

The Telangana High Court clarifies that vehicles seized for allegedly carrying PDS rice may be released during pendency of Essential Commodities Act confiscation proceedings, subject to conditions. The judgment applies established High Court precedent and is binding on subordinate courts in Telangana, with practical guidance for similar release applications.

 

Summary

Category Data
Case Name WP/31162/2025 of Kadamanchi Rajaiah Vs The State of Telangana
CNR HBHC010617452025
Date of Registration 13-10-2025
Decision Date 15-10-2025
Disposal Nature DISPOSED OF NO COSTS
Judgment Author Justice T. Madhavi Devi
Court High Court for the State of Telangana
Bench Single Judge Bench (Justice T. Madhavi Devi)
Precedent Value Binding within the jurisdiction of Telangana High Court
Overrules / Affirms Affirms previous High Court order in W.P.No.657/2024 dated 09.01.2024
Type of Law Administrative / Criminal—Essential Commodities Act
Questions of Law Whether a vehicle seized for alleged transportation of PDS rice can be released pending confiscation proceedings.
Ratio Decidendi
  • The High Court reiterated that vehicles seized in connection with alleged violations of the Essential Commodities Act, specifically for carrying PDS rice, may be released to the owner on furnishing a specified security and appropriate undertaking, pending the outcome of confiscation proceedings.
  • The release is conditional on furnishing a bank guarantee by way of fixed deposit and a written undertaking not to alienate or encumber the vehicle.
  • The approach aligns with prior High Court rulings on interim release, balancing interests of the State and the property rights of the vehicle owner.
  • These interim measures do not prejudice the outcome of the confiscation proceedings under Section 6-A of the Essential Commodities Act.
  • The judgment expressly follows and applies precedent set in W.P.No.657/2024.
Judgments Relied Upon W.P.No.657/2024 (Order dated 09.01.2024)
Logic / Jurisprudence / Authorities Relied Upon by the Court The Court relied on its previous order in similar circumstances to release the seized vehicle on appropriate conditions, with the State not disputing the applicability of the precedent.
Facts as Summarised by the Court The petitioner’s Eicher vehicle was seized by the authorities on the allegation of carrying PDS rice by the accused in Cr.No.508/2025. The petitioner sought release of the vehicle, challenging the seizure as illegal and arbitrary, and requested interim release pending the outcome of confiscation proceedings. Respondents did not dispute the factual background or the applicability of the previous precedent.

Practical Impact

Category Impact
Binding On All subordinate courts within the jurisdiction of the Telangana High Court
Persuasive For Other High Courts, in the absence of contrary precedent
Follows W.P.No.657/2024 (Telangana High Court, Order dated 09.01.2024)

What’s New / What Lawyers Should Note

  • The High Court reiterates that vehicles seized for alleged violation of the Essential Commodities Act (carrying PDS rice) can be released on security and undertaking, even before the conclusion of confiscation proceedings.
  • The release is expressly made conditional on (a) furnishing a bank guarantee by way of fixed deposit for Rs.25,000 in favour of the Civil Supplies Department and (b) an undertaking not to alienate, alter, or encumber the vehicle.
  • The release order will not affect the subsequent confiscation proceedings under Section 6-A of the Essential Commodities Act.
  • This order confirms and follows the precedent set in W.P.No.657/2024, making practice uniform for similar future petitions.

Summary of Legal Reasoning

  • The petitioner sought interim release of a seized vehicle, citing a previous High Court order (W.P.No.657/2024) granting similar relief.
  • The court considered submissions from both the petitioner’s counsel and government pleaders (Civil Supplies and Home), who did not dispute the applicability of the cited precedent.
  • The court reasoned that, consistent with its earlier decision in W.P.No.657/2024, interim release should be granted upon the petitioner furnishing a fixed deposit bank guarantee for Rs.25,000 and an undertaking concerning the vehicle’s status.
  • The court clarified that the release is subject to the ongoing confiscation proceedings under Section 6-A of the Essential Commodities Act and does not decide the legality of the original seizure.
  • The court concluded that imposing such conditions balances the interests of the petitioner and the respondents pending final adjudication.

Arguments by the Parties

Petitioner

  • Contended that in similar circumstances in W.P.No.657/2024, the High Court had directed release of the seized vehicle with certain conditions and sought similar relief.

Respondents (State/Civil Supplies and Home)

  • Did not dispute the petitioner’s factual and legal submissions regarding the applicability of the prior order and the possibility of conditional release.

Factual Background

The petitioner’s Eicher vehicle was seized by authorities alleging it was used to carry Public Distribution System (PDS) rice in Cr.No.508/2025. The petitioner challenged the seizure as illegal and arbitrary, seeking release of the vehicle by the Station House Officer, Armoor, Nizamabad District. The vehicle’s interim release was sought pending the outcome of confiscation proceedings under the Essential Commodities Act.

Statutory Analysis

  • Section 6-A of the Essential Commodities Act, 1955, governing confiscation proceedings for vehicles allegedly used in contravention of the Act, is implicated.
  • The court’s release order is made expressly “subject to the outcome of the confiscation proceedings under Section 6-A of the Essential Commodities Act, 1955.”
  • No expansive or restrictive interpretation of Section 6-A is undertaken; the release is interim and procedural in character, not affecting the merits.

Dissenting / Concurring Opinion Summary

No dissenting or concurring opinions are recorded in the judgment.

Procedural Innovations

No new procedural rules or substantive procedural innovations are introduced in the judgment. The judgment follows established process set by the High Court in similar cases.

Alert Indicators

  • ✔ Precedent Followed – When existing law is affirmed.

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